## Facts

- Iron Grip Barbell Company, Inc. owned U.S. Patent No. 6,436,015 covering a barbell weight plate with a central throughbore and “solely a triad” of equiangular elongated handle openings forming three integral grips for one-handed transport.
- Traditional weight plates were difficult to grasp and carry; handle openings were a known solution to this problem.
- Prior art disclosed weight plates with one elongated grip opening (U.S. Patent No. 4,199,140), two elongated grip openings (U.S. Patent No. 5,137,502), and a plate with four openings (U.S. Patent No. 4,618,142).
- After the ’015 patent issued, USA Sports produced a three-grip plate accused of infringing; Iron Grip asserted USA Sports had “copied” Iron Grip’s design.
- The district court held asserted claims 1–3 and 6–8 invalid as obvious under 35 U.S.C. § 103; Iron Grip appealed.

## Issues

1. Whether claims 1–3 and 6–8 were invalid as obvious under 35 U.S.C. § 103 where prior art taught weight plates with one, two, and four grip openings and the claimed difference was three equiangular openings.
2. Whether secondary considerations—alleged copying and commercial success—rebutted any prima facie showing of obviousness.

## Decision

- The Federal Circuit affirmed the judgment that claims 1–3 and 6–8 were invalid for obviousness.
- The court held the claimed advance differed from the prior art only in the number and placement of grip openings, a predictable variation of known designs.
- The court found Iron Grip’s copying evidence insufficient because it did not show replication of a specific product through concrete proof (e.g., internal documents or reverse engineering of a product).
- The court found commercial success evidence insufficient absent a demonstrated nexus between the claimed three-opening configuration and the asserted sales success.

## Legal Principles

- When prior art teaches the general functional solution, changing only the number and arrangement of known structural features can be an obvious design variation absent unexpected results.
- Copying as a secondary consideration requires evidence of replication of a specific product (not merely making an accused product within the patent’s scope), shown by concrete proof such as internal documents, direct reverse engineering evidence, or access plus substantial similarity to the product.
- Commercial success is relevant to nonobviousness only if there is a nexus between the commercial performance and the claimed features, rather than unclaimed attributes or market factors.

## Conclusion

The Federal Circuit held the asserted claims obvious because prior art already taught grip-opening solutions and the claimed three equiangular openings reflected only a routine choice among predictable configurations; alleged copying and commercial success did not carry sufficient evidentiary weight to overcome the obviousness showing.


Iron Grip Barbell Co. v. USA Sports, Inc., 392 F.3d 1317 (Fed. Cir. 2004)